In August 2019, the Commission adopted rules implementing two federal laws that strengthen emergency calling:  Kari’s Law and Section 506 of RAY BAUM’S Act.

Kari’s Law – Direct Dialing and Notification for MLTS

Kari’s Law is named in honor of Kari Hunt, who was killed by her estranged husband in a motel room in Marshall, Texas in 2013.  Ms. Hunt’s 9-year-old daughter tried to call 911 for help four times from the motel room phone, but the call never went through because she did not know that the motel’s phone system required dialing “9” for an outbound line before dialing 911.

Congress responded by enacting Kari’s Law in 2018.  Kari’s Law requires direct 911 dialing and notification capabilities in multi-line telephone systems (MLTS), which are typically found in enterprises such as office buildings, campuses, and hotels.  The statute provides that these requirements take effect on February 16, 2020, two years after the enactment date of Kari’s Law.   In addition, Kari’s Law and the federal rules are forward-looking and apply only with respect to MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.

Under the statute and the Commission’s rules, MLTS manufacturers and vendors must pre-configure these systems to support direct dialing of 911—that is, to enable the user to dial 911 without having to dial any prefix or access code, such as the number 9.  In addition, MLTS installers, managers, and operators must ensure that the systems support 911 direct dialing.

The Commission’s rules also implement the notification requirement of Kari’s Law, which is intended to facilitate building entry by first responders.  When a 911 call is placed on a MLTS system, the system must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification.

Compliance date:  Compliance with the rules implementing Kari’s Law is required beginning February 16, 2020.

RAY BAUM’S Act – Dispatchable Location for MLTS

Under Section 506 of RAY BAUM’S Act, the Commission adopted rules to ensure that “dispatchable location” is conveyed with 911 calls to dispatch centers, regardless of the technological platform used, including 911 calls from multi-line telephone systems.  Dispatchable location includes the street address of the caller and additional information, such as room number and floor number, necessary to identify the caller’s location for first responders.  For further information on dispatchable location requirements applicable to MLTS, see Dispatchable Location web page.


911 Requirements for MLTS – 47 C.F.R. Part 9, Subpart F

The FCC will closely monitor any complaints about alleged violations of these 911 rules.

  • Public Safety Answering Points (PSAPs), also known as 911 call centers, and other public safety entities may request support from the Public Safety and Homeland Security Bureau and notify it of problems or issues affecting the provision of emergency services through the Public Safety Support Center.


Report and Order – Implementing Kari’s Law and Section 506 of RAY BAUM’S Act (Aug. 1, 2019)

Erratum – Implementing Kari's Law and Section 506 of RAY BAUM'S Act (PSHSB Dec. 2, 2019)

Public Notice – Announcing Jan. 6, 2020 Effective Date for Rules Implementing Kari’s Law and Section 506 of RAY BAUM’S Act (PSHSB Dec. 5, 2019)

Notice of Proposed Rulemaking – Implementing Kari’s Law and Section 506 of RAY BAUM’S Act (Oct. 26, 2018)

Notice of Inquiry – FCC to Examine 911 Capabilities of Enterprise Communications Systems (Sept. 26, 2017)

Thursday, January 23, 2020